Plaintiff Joyce A. Taylor Haynie sued defendant Washington University School of Medicine Division of Infectious Diseases in the United States District Court for the Eastern District of Missouri, raising claims of race discrimination and retaliation under Title VII and the Missouri Human Rights Act. Before the court is Defendant’s post-trial motion for bill of costs.
Statement of Facts
Plaintiff Joyce A. Taylor Haynie filed a pro se complaint against Washington University School of Medicine Division of Infectious Diseases, alleging violations of Title VII and the Missouri Human Rights Act for race discrimination and retaliation. Initially granted permission to proceed in forma pauperis, Plaintiff later obtained counsel and filed a Second Amended Complaint. Defendant subsequently moved for summary judgment, which the court granted, dismissing the case with prejudice.
The court concluded that Plaintiff failed to demonstrate a prima facie case of employment discrimination under Title VII, and even if she had, the record showed that Defendant’s reason for terminating her was not pretextual. The court also found that Plaintiff’s MHRA claims were not timely filed and, even if they were, would fail for the same reasons as the Title VII claims.
As the prevailing party, Defendant filed a motion for bill of costs, seeking to recover $9,657.61 in various litigation expenses. Plaintiff objected to certain costs, arguing they lacked statutory authorization and that assessing any costs would place an unreasonable financial hardship on her.
Legal Analysis
Prevailing Party’s Right to Costs: The court noted that under Federal Rule of Civil Procedure 54(d), there is a presumption that the prevailing party be awarded costs. However, the district court retains substantial discretion in awarding costs to the prevailing party.
Deposition Costs: The court analyzed the deposition costs sought by Defendant, which totaled $9,551.30. While allowing most of the transcript fees, the court disallowed certain additional charges such as “Professional Attendance,” “Logistics, Process & Electronic Files,” and “Litigation Services & Logistics,” finding these costs were not statutorily authorized under 28 U.S.C. § 1920.
The court also denied costs for video recordings of Plaintiff’s depositions, totaling $3,768, reasoning that these were not necessary given the circumstances of the case and the timing of the summary judgment motion.
Certified Copy of Unemployment Record: The court allowed the cost of obtaining a certified copy of Plaintiff’s unemployment record, finding it was necessarily obtained for use in the case. However, the court disallowed the associated shipping fee.
Plaintiff’s Financial Status: The court considered Plaintiff’s argument that assessing costs would cause her undue financial hardship. While not outright denying Defendant’s request for costs, the court found a reduction appropriate in light of Plaintiff’s financial situation and her initial in forma pauperis status.
The court granted Defendant’s motion for bill of costs in part, reducing the amount from the requested $9,657.61 to $1,500.00 to be taxed against Plaintiff.
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